Issue: Whether expense incurred in psychotherapy for the treatment of eating disorders are "medical expenses" within the meaning of a separation and support decree

Index Topics: Psychologists' Scope of Practice/Reimbursement for "Mental Health" Services

Facts: As part of a divorce decree, a father was required to pay all medical, dental and orthodontia expenses for his minor children in excess of a certain amount per year if not covered by insurance. One of the children developed severe eating disorders for which the mother sought treatment by a licensed psychologist. The bills for treatment amounted to more than $10,000. The father refused to pay any of the outstanding bills, claiming that the services were not medical expenses as contemplated under the divorce decree because they were not provided by a physician. The trial court found that the father was required to pay for the treatment. The father appealed that decision.

APA's position: APA submitted an amicus brief arguing that the trial court correctly interpreted the judgment and dissolution as requiring the father to pay for treatment for a child suffering from anorexia, bulimia, and adjustment disorders because: (1) the term 'medical expenses' is commonly understood to include psychologists' services for serious disorders; (2) the parties' reasonable intent was to include the services; and (3) treatment for anorexia and bulimia was a medical expense. The brief also argued that sessions with the mother to aid the child's treatment were valid medical expenses.

Result: The Connecticut Court of Appeals upheld the trial court's finding that services by a psychologist in treating bulimia and anorexia were medical expenses and that the treatment rendered was a necessary part of the overall treatment of the child.